Corrective Action Plans

Program: Various, including 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds; 10.555 – National School Lunch Program – Reporting Corrective Action Plan: State Accounting will continue to work with State agencies on correct coding and business unit setup to reduce agency errors. Contact: Philip Olsen Anticipated Completion Date: Continuous review performed.

Condition: The City did not accurately prepare a SEFA that included all federal expenditures in fiscal year 2025, which resulted in a difference of approximately $7.6 million. Planned Corrective Action: The City will ensure that all future expenditures of federal awards are included on the SEFA by assigned staff to prepare and review the SEFA and track the amounts throughout the year. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026

The Authority will develop and implement a standardized fiscal year transition and grant charging process to ensure controls are in place for accurate and timely recording of grant eligible expenditures. As part of this process, the Authority will develop a verification checklist for all funding source reclassification journal entries to ensure compliance prior to posting. This process will: - Identify all stakeholders responsible for year‑end grant reconciliation and reporting. - Establish a required review and approval process to be completed before any change in funding source or charging mode. - Update Accounting Policies and Procedures Manual to include guidelines to limit reclassification of expenditures incurred in prior fiscal years. - Set a formal annual cut-off date for Program Offices to request current year funding source reclassifications, allowing sufficient time for the Funds and Grants Management team to review and meet fiscal year‑end reporting deadlines. - Refine current monitoring mechanism for “yet‑to‑bill” transactions throughout the fiscal year for transferred transactions that originated in the general ledger to ensure all federal expenditures incurred within the period are reviewed and reported in accordance with the accrual basis of accounting. - Ensure the requirements for eligibility of expenses for Federal grants from 2 CFR 200.403 are enforced.

Responsible Person(s): Darin Moore, Deputy Director of Administration and Outreach; Sarah Boggs, Accounting Manager for Planning and Finance; Suzanne Robinson; Tim Springer, Budget Manager for Planning and Finance Corrective Action Planned: Review the current DWR process and determine whether DWR should petition the Comptroller for an exception to CAPP Topic 20605 or modify the DWR process to the “split coding” method instead. This will include: 1.) Evaluation of grant program guidance to ensure no obstacles exist from the Federal Awarding Agency to changing DWR's current methodology; 2.) Meeting and discussing with other (like) state agencies for policy, procedure, and training examples for split coding grant eligible expenditures; 3.) Scheduling meetings with Department of Accounts and the previous APA Audit Team to discuss DWR's evaluation, decision, and next steps; 4.) Developing and implementing new DWR policies and training to ensure compliance with the approved methodology. (Estimated completion date: July 1, 2026) Update current policies and procedures to conform with CAPP Manual Topic 20405 and to enhance the agency's current supporting documentation for all journal entries. At a minimum, these new policies and procedures will require that Voucher ID/Expense Report IDs that are moved within a journal entry are documented in the journal reference line in the system to improve transparency, will add more detailed explanations to justify coding changes, will upload applicable documents into the system to assist in manager approval, and will maintain all documentation centrally in one location for easier access and review. (Estimated completion date: July 1, 2026) Publish and maintain a sustainable federal drawdown schedule, by: 1.) Evaluating DWR's current federal drawdown schedule in accordance with current policies, procedures, employee workload, cashflow, and Federal Awarding Agency's guidance; 2.) Developing specific controls, and revised job descriptions as needed to ensure the drawdown schedule can be consistently maintained; and 3.) Incorporating both the new schedule and controls into appropriate policies and procedures to ensure accountability. (Estimated completion date: June 1, 2026) Evaluate current policies, procedures, and practices pertaining to how DWR manages and records Program Income. Develop and update policies and procedures to ensure compliance with CAPP 20205. Provide training on new policies and procedures to employees within the Planning and Finance Division. (Estimated completion date: June 1, 2026) Review current internal procedures for reporting federal expenses on the SEFA and Attachment 15 and identify training gaps. Enlist training support from Department of Accounts and/or other state agencies to address training gaps. Develop new written policies and procedures, along with new supporting documentation requirements, to conform to SEFA and Attachment 15 guidelines and expectations. Provide training on new policies and procedures to employees within the Planning and Finance Division. (Estimated completion date: July 1, 2026) Review all other written policies and procedures for administering federal grants and contracts, and develop and update as necessary to address insufficient guidance and noncompliance. (Estimated completion date: August 31, 2025) Estimated Completion Date: 7/1/2026

Reference Number: 2025-001 Name of Contact Person: Julie Bondarchuk, Financial Controller Corrective Action: The expenditure occurred in calendar year 2020 and 2021. Since these funds were emergency funds, no deferred revenue was accrued since staff was uncertain of whether costs would be eligible for reimbursement. Final revenues of $101,355 were received in FY2025, and staff recorded the revenue received on the SEFA, but not the expenditure. Going forward, staff will report expenditures on the SEFA when eligible expenditures are approved by FEMA. Proposed Completion Date: 6/30/2026

Views of responsible officials and corrective action: The organization hired an individual contractor to assist with the implementation of a formal financial closing process, which includes identifying a detailed and specific process to review and reconcile procedures to ensure accurate reporting of federal expenditures and alignment with the general ledger. Responsible Individual: Okeema Polite, CEO/Executive Director Todd Falcone, Independent Contractor Bookkeeper Vannessa Lindsey, Board President Implementation Date: ACAC has begun implementing the procedures with the assignment to the Independent Contractor as of May 2025. Recommended procedures will be implemented by July 30, 2026

Views of Responsible Officials and Planned Corrective Action The County fully implemented a grant software program in FY 2026 to provide accurate and complete tracking and reporting of federal award expenditures. Finding resolution timeline: This has been resolved as of 12/4/2025. Designation of employee position responsible for meeting this deadline: Andrea Montoya (Deputy County Manager), Gabriella (Betty) Orosco (Assistant Finance Director) and Francine Mondello( Grant Administrator)

Management acknowledges the deficiency in the preparation and oversight of the Schedule of Expenditures of Federal Awards (SEFA) for the year ended May 31, 2025. To address this finding, the College will: • Implement a formal SEFA preparation policy aligned with 2 CFR §200.510(b) • Develop and maintain a centralized federal awards tracking log identifying: o Federal agency o Program name o Assistance Listing Number (ALN) o Award number o Pass-through entity (if applicable) o Expenditures by fiscal year • Establish quarterly reconciliations between the general ledger and the federal awards tracking log • Require structured cross-departmental communication between the Business Office, Financial Aid Office, Grants Administration, and program departments to ensure all federal awards received and expended are identified timely • Implement documented management review and approval of the SEFA prior to submission to auditors These corrective measures will strengthen internal controls over federal award tracking, improve the accuracy and completeness of the SEFA, and ensure compliance with Uniform Guidance requirements. Anticipated Completion Date: May 31, 2026

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: Implementation of a formal procurement and suspension and debarment policy that includes procedures over review of the federal suspension and debarred listing, that is in compliance with the Uniform Guidance. Procurement policy should include general procurement standards as described by the Uniform Guidance, that include standards on conduct covering conflicts of interest; method of procurement for micro-purchases, small purchases, sealed bids, and proposals; and all other criteria as outlined in 2CFR 200.318 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will develop and implement a procurement policy that is in compliance with the Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Sydney Falk, CFO Planned completion date for corrective action plan: February 28, 2026

RE: Finding 2025-003 Misreporting of Pass-Through Grant Expenditures in Compliance Report In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will strengthen internal controls over federal grant reporting to ensure proper distinction between direct federal awards and federal pass-through grants, in accordance with Uniform Guidance and SLFRF requirements. Specifically, the City will implement the following corrective actions: Separate Tracking of Direct vs. Pass-Through Funds o The Finance Department will revise grant accounting procedures to clearly segregate expenditures related to: Direct SLFRF (ARPA) awards administered by the City, and Federal pass-through grants administered by external entities, including OWRB. o Separate project codes and/or accounting identifiers will be maintained to prevent commingling of expenditures. Revision of SLFRF Reporting Procedures o Written procedures for preparation and review of the SLFRF Compliance Report will be updated to explicitly state that: Only expenditures related to direct federal awards are to be reported by the City, and Expenditures related to pass-through grants are excluded and reported by the pass-through entity. o A documented review step will be added to verify that reported expenditures align with the funding source prior to submission. Staff Training and Awareness o Finance staff involved in grant accounting and reporting will receive targeted training on: Uniform Guidance requirements (2 CFR 200), The distinction between direct federal awards and pass-through grants, and Proper SEFA and SLFRF reporting responsibilities. o Training will be documented and incorporated into onboarding materials for future staff. Coordination with Pass-Through Entity (OWRB) o The City will coordinate with OWRB to confirm: The sequence of fund utilization (pass-through vs. direct ARPA funds), and Roles and responsibilities for federal expenditure reporting. Expected completion date: Procedures will be implemented for the fiscal year ending June 30, 2026, and applied during interim processing and year-end close. Party Responsible: Finance Director and Finance Staff, in coordination with applicable Department Heads and Project Managers. Contact Information: Arlena Barnes 918-246-2646 arlena.barnes@sandspringsok.gov

The District will implement procedure to ensure that grant activity is charged during the proper period and sufficient documentation is maintained.

Condition: Controls were not in place to ensure that the schedule of expenditures of federal awards (SEFA) was complete and accurate. Planned Corrective Action: The Village has hired an outside contractor to assist with review of audit documents. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2025

By requiring Finance Department signatures for all grant applications, a comprehensive list of all potential program awards can be maintained. From this information, potential expenditures can be monitored for the awards inclusion on the SEFA.

Finding Number: 2025-002 Condition: Lakeland did not have adequate controls in place to ensure the SEFA was prepared to include appropriate expenditures for the Economic Development Cluster in the proper period. Planned Corrective Action: The College will establish the proper controls to ensure that the SEFA is prepared based on the timing of the underlying activity rather than payment dates. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: December 2025

Finding Number: 2025-001 Condition: The 2025 Schedule was initially overstated to include federal awards relating to ALN 14.251, Economic Development Initiative, Community Project Funding, and Miscellaneous Grants, expended during the year ended June 30, 2024. Planned Corrective Action: Food Bank of the Rockies, Inc. received a reimbursement grant for vehicles from the Department of Housing and Urban Development (HUD). While we purchased the vehicles in fiscal year 2024, we could not file the claim for reimbursement until fiscal year 2025. Guidance on the HUD claims process was greatly delayed for multiple reasons. We posted the cost and asset when ordered, following accounting principles generally accepted in the United States (GAAP). However, we did not include the funding on the 2024 Schedule as we had not yet filed the reimbursement claims, nor been given assurance they would be paid. Instead, we included it in the fiscal year 2025 Schedule as that was when the claims were filed and we had confirmation they would be paid in full. We understand now that, per Uniform Guidance 2 CFR 200.51(b), those funds should have been shown the fiscal year 2024 Schedule. With this understanding, moving forward we will include in the Schedule amounts that have been spent for which we have an agreement for reimbursement, regardless of timing of the claim being filed or level of certainty of reimbursement. Contact person responsible for corrective action: Heather MacKendrick Costa Anticipated Completion Date: Completed

2025-002 SEFA Presentation Error – Prior Year Criteria: Uniform Guidance (2 CFR §200.510(b)) requires that the Schedule of Expenditures of Federal Awards (SEFA) accurately present all federal awards, including the correct identifying numbers assigned by pass-through entities for each award. Accurate reporting is essential to ensure compliance with funding requirements and enable proper tracking and monitoring of federal awards. Client’s Response: Last year was the organization’s first time going through a Single Audit. Although the organization accurately tracked expenditures corresponding to the grant award, the transactions were charged to an unrestricted program. The correction was detected and corrected during this fiscal year. We have implemented the necessary internal controls to ensure that our grant reporting accurately reflects the expenditures for each of our respective grants. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

Corrective Action Plan Finding 2025-001 Federal Award Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance – Reporting Name of Contact Person Kimberly Carlo, Executive Director Corrective Action In this case it was noted that our Organization did not perform reconciliation procedures between the federal program reporting of direct client expenditures with our financial accounting records. Not performing this reconciliation lead to an unreconciled difference when determining whether the data was complete and accurate. We have thoroughly reviewed our internal procedures, identified weaknesses and implemented changes to assure this will never happen again. To prevent and detect such errors in the future, we have changed our internal procedures to include: Project files that are being closed and reported to the grantor are being reviewed on a monthly basis. During the review, project files will be verified that the funding sources used for expenditures reconcile with the funding sources used for payment as recorded in the financial accounting records. Any differences will be reconciled at this point and such documentation will be retained. Additionally, an annual reconciliation of all population data used for program expenditures will be reconciled with our financial accounting records. To prevent and detect such errors in the future, we have changed our internal procedures to include: 1. Each material list along with measures and funding sources will be printed for the client file for direct material and labor charges. 2. The financial coordinator will verify funding sources match with amounts reported in the financial accounting records. 3. Any changes to funding for material and labor will be printed for the client file and given to the financial coordinator to change funding sources in the IWI accounting system. 4. Once funding is changed, verification will be printed for the client file. 5. An annual reconciliation of client program expenditures will be reconciled with our revenue and expenditure report for each funding source. Implementation Immediate.

Recommendation: We recommend management establish an informal procedure to reconcile grant funds received with funds expended on a regular basis. We also recommend management implement a formal procedure to reconcile the SEFA with the general ledger at year end. Corrective Action: The Comptroller will reconcile this report on a monthly basis making sure that all grants and other Federal / State expenditures are on the SEFA and that the two numbers reconcile with the general ledger. This will be kept in a notebook and the calendar kept in the Comptroller’s desk. The Comptroller will also create a folder in the business office folder on the server and input the current SEFA in this folder and show any discrepancies on a monthly basis and every time this report is run for drawdowns. This process will start immediately. The Comptroller will also make sure at year end that all items are on this report and they have been reconciled with the general ledger. This process will also be in the notebook and calendar within the desk of the Comptroller.

Other finding – SEFA Preparation Preparation of Schedule of Expenditures of Federal Awards Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury Recommendation: The Corporation should update its policies and procedures and internal controls to ensure accurate reporting of the Schedule as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA department created a standard pre-award approval process for all sponsored proposals prior to submission or award acceptance. The pre-award approval process applies to all federal, state, local, private and commercial funding opportunities across all UMMS entities and covers new, renewal, resubmission and supplemental proposals. The establishment of a central intake process through one department, for all grants across the Corporation, enhances the controls to ensure complete and accurate reporting of the Schedule as required by the Uniform Guidance. Additionally, ORSPA and Corporate Financial Reporting implemented the following controls to ensure all expenditures of federal awards are included on the Schedule. These controls include:  Reconciliation of the grants from the pre-award approval process to the grants tagged in the accounting system;  Use of a specific grant identifier within the accounting system to track expenditures and revenue recognition and tag grants as federal, state or private funded;  Comparison of grant expenditures per the accounting system to the grant agreement;  Comparison of grant expenditures per the accounting system to the financial reporting submissions made to the federal agencies;  Certification from legal entity Finance Executives that the draft Schedule is complete and accurate;  Comparison of the prior year Schedule to the current year Schedule with further investigation around changes in grants and agencies included, and significant changes in the expenditures. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

Management has taken steps to contract an audit firm and is currently working with the auditors to perform the single audit for the fiscal year ended June 30, 2025, with anticipation of completion before the deadline of March 31, 2026. Management has also prepared a Schedule of Expenditures of Federal Awards for the fiscal year ended June 30, 2025.

Scotland County’s response for issues found: 1. We will double check to make sure we didn’t miss something for the SEFA report. 2. We will update the 2024 SEFA for the corrected amounts. 3. The Highway Planning and Construction (MODOT Intermodal) included the railroad bridge that no one could tell us where the money was coming from. This accounted for $1,228,104.64. We will correct this on the SEFA. 4. The ARPA was the interest received in 2024. We didn’t receive any more money from the state in 2024. We will get this added to the SEFA. 5. The HAVA Election Security Grant was missed when we were putting them in the report. We will get this added to the SEFA.

Finding Number: 2024-002 Finding Title: Incomplete Schedule of Expenditures of Federal Awards Federal Program Information: • Federal Agency: Department of the Treasury • Assistance Listing Number (ALN): 21.027 • Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Reporting - Schedule of Expenditures of Federal Awards (2 CFR §200.510(b)) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization was unaware that pass-through funds from federal sources are required to be presented on the SEFA and has implemented procedures to ensure all grants are evaluated to ensure the SEFA is complete. Corrective Action Plan: Corrective Action #1: Federal Award Identification and Tracking System • Action: Create comprehensive federal awards tracking log including all direct and pass-through awards. Implement quarterly review process where Board members and Contract Accountant meet to identify all federal awards. Develop checklist to determine SEFA inclusion requirements. Board President will maintain master list of all grant agreements. • Responsible Person/Title: Board President and Contract Accountant • Anticipated Completion Date: January 15, 2026 Corrective Action #2: SEFA Reconciliation Procedures • Action: Establish quarterly procedures to reconcile SEFA to general ledger. Cross-reference all grant agreements and award letters. Document reconciliation process with dual sign-off from Contract Accountant and Board Treasurer. • Responsible Person/Title: Contract Accountant • Anticipated Completion Date: January 31, 2026 (initial); Ongoing quarterly thereafter Corrective Action #3: Independent Review Process • Action: Implement mandatory Board Treasurer independent review of SEFA prior to audit commencement. Treasurer will verify completeness by tracing to source documents. Present draft SEFA to full Board for review before finalizing. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Annually, beginning with FY 2025 audit Corrective Action #4: Training • Action: Provide training to Contract Accountant and all Board members on SEFA requirements, including identification of federal awards and pass-through funding, and Board oversight responsibilities. • Responsible Person/Title: Board President • Anticipated Completion Date: February 28, 2026

Root Cause Management concurs that federal expenditures totaling approximately $5,842,346 under ALN 21.029 were omitted from the initially prepared SEFA, along with an additional $206,139 of other federal programs, for a total of $6,048,485. Additionally, management discovered that $2,786,421 was omitted from the June 30, 2024 SEFA. The omission resulted from incomplete grant tracking reports not reconciled to the general ledger and grant agreements; absence of an independent secondary review; and procedures that did not fully capture pass-through and subrecipient activity. Objective Design and implement effective internal controls to ensure the SEFA is complete, accurate, and in compliance with 2 CFR §200.510(b) and §200.303; prevent recurrence of material omissions; and sustain readiness for Single Audit reporting. 1. Comprehensive Reconciliation Process Implement a standardized monthly and year-end reconciliation that ties federal award expenditures (including drawdowns and indirect costs) to the general ledger, award agreements/portals, and program manager reports. Create a SEFA Reconciliation Workbook with crosswalks by ALN, passthrough entity, award number, program, and period of performance. 2. Federal Awards Inventory & Certification Maintain a centralized Federal Awards Inventory listing all awards by ALN, award number, passthrough entity, and funding stream. Require annual certifications from responsible leadership team members confirming completeness and accuracy of reported expenditures and period-of-performance coverage. 3. Formal Review Workflow (Independent of Preparer) Establish a documented two-tier review: (1) VP of Finance prepares SEFA and reconciliation; (2) Leadership Team Members perform independent reviews using a SEFA Checklist covering ALNs, pass-throughs, subrecipient disclosures, notes (basis, indirect cost rate), and period-of-performance matching. Evidence the review via dated sign-offs. 4. Subrecipient & Pass-through Controls The VP of Finance create procedures to identify all pass-through and subrecipient transactions. Maintain subrecipient listings with amounts passed through and ensure required disclosures (ALN, pass-through numbers) are captured in SEFA. Reconcile subrecipient agreements and payment registers to SEFA. Leadership Team Members perform independent reviews for accuracy and completeness. 5. Close Calendar & Training Adopt an annual SEFA close calendar with milestones (pre-close, interim, final). Provide annual training for finance and program staff on Uniform Guidance reporting requirements and the SEFA Checklist; include updates to OMB Compliance Supplement as applicable. 6. Monitoring & Continuous Improvement Quarterly CAP monitoring by VP of Finance with status reports to the Finance Committee. Track metrics (e.g., % variance between GL and SEFA, number of checklist exceptions) and remediate promptly. Conduct a pre-audit SEFA "dry run" at least 60 days before year-end close. Roles & Responsibilities • VP of Finance: CAP owner; oversight, quarterly monitoring, reports to Finance Committee, designs reconciliation and review workflow; ensures adherence to checklist and certifications; prepares SEFA, reconciliation workbook, and supporting schedules. • Responsible Leadership Team Member/Program Managers: Certify award activity and completeness; provide supporting documentation. Timeline & Milestones Immediate (within 30 days): Approve CAP; establish Federal Awards Inventory template; draft SEFA Checklist; schedule training. Short term (within 60-90 days): Implement monthly reconciliation; obtain program certifications; pilot independent review on QI data. By next year-end close: Execute full close calendar; complete pre-audit SEFA dry run; document reviewer sign-offs; present monitoring results to Finance Committee. Compliance References • 2 CFR §200.510(h): SEFA preparation requirements (completeness, ALN, pass-through, etc.). • 2 CFR §200.303: Internal controls over federal awards. Management Statement (for 2 CFR §200.511(c) submission) Management agrees with the finding and has initiated the corrective actions described herein. The CAP will be monitored quarterly by the VP of Finance, with status updates provided to those charged with governance until all actions are fully implemented and operating effectively.

The City will ensure that all future expenditures are tracked and reported to the proper periods and recorded appropriately.

The City will ensure that all future awards under this program are in compliance and separately report on the Schedule of Expenditures of Federal Awards. All pass-through expenditures will be reconciled to ensure accuracy going forward.